Court of Appeals Sanctions Attorney for AI-Generated Fake Citations and Vexatious Appeal
An attorney who submits filings containing fabricated or unsupported legal authority—including hallucinated citations generated by artificial intelligence—violates the duty of reasonable inquiry under MCR 1.109(E)(5), and such conduct on appeal supports sanctions under MCR 7.216(C)(1).
Court of Appeals Holds Framework for Calculating Reasonable Attorney Fees Applies to MCR 1.109 Sanctions
The Court of Appeals finds the framework for calculating reasonable attorney fees under the Supreme Court’s holdings in Smith/Pirgu applies to sanctions under MCR 1.109
Law Firm Is Jointly & Severally Liable For Attorney Fee Sanctions
The trial court also held the defendant’s former legal counsel, the law firm of Neda, Camaj & Fakhouri, PC, jointly and severally liable for the fees. The law firm appealed the ruling.